Vendor Guru Q&A - Compliance

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Latest Compliance - Reg. BB Topics

How to Report Revolving Lines of Credit (Extended)

10/01/2017

I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged. For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?

CRA Reporting of Gross Revenue (Reg BB)

08/13/2017

The CRA regulation states, "generally, an institution is to rely on the revenues that it considered in making its credit decision." It also states, "The regulation does not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, the agencies expect them to collect and rely upon the borrowers' gross revenue for purposes of CRA." Does one of these trump the other? We use personal income for the credit decision and rarely use gross revenues of the business. Our auditors think the "credit decision" amounts outweigh using what we have in the file. If we only used the credit decision amounts, we wouldn't have many loans to report.

Documentation to Prove Community Development Loan

05/25/2015

What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.

Credit Reduction for Extension of IR Lock

08/18/2019

Regarding a lender credit reduction for an extension of an interest rate lock, may a lender reduce a lender credit to extend the lock period? Example; A rate lock expired 4-25-19 and the closing date was 4-28-19. The initial rate lock and Loan Estimate reflect a lender credit of $2000.00 with 4.25% interest rate. The lock was extended through 4-29-19 at the same rate, but the lender credit was reduced to 1800.00. Since the lender credit was reduced based on an interest rate dependent charge, is this acceptable for interest rate extensions? If it is, is there a requirement that documentation confirms the delay was due to the borrower or outside of the lenders control?

Reg D Apply to Savings Used as Security for Loan?

08/18/2019

Does Reg D apply to a savings account that has been used as security for a loan?

Advertising rates

08/18/2019

If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?

Lobby Advertising

08/11/2019

We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement.

Stop Payment Order for Expense Checks

08/11/2019

Is there a minimum or maximum length of time that a stop payment order for Expense Checks is applicable?

Latest Compliance - Reg. BB Topics

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